Rafi Ullah Khan, Manager(Cartography & Survey) Resource Mapping Division, HQ’s Office

Lahore.

SUBJECT: STATEMENT ON ACCOUNT OF THE ROLE OF OFFICER (ACCUSED) NOMINATED

IN FIR NO. 43035-03/19 THANA DACE PUNJAB LAHORE DATED 12-09-2019
LODGED BY THE ANTI-CORRUPTION ESTABLISHMENT.

That the committee of ACE investigating the matter in respect of above FIR directed the
officer/accused to submit the concise statement in defense against the inquiry finding mentioned in
above FIR and their respective regular role/domain in Mines and Minerals department.

In this regard, in compliance with above directions the statement in comprising all
possible aspects are briefly explained as under:-

1. It is worth mentioning that Directorate General of Mines and Minerals comprises six
divisions(organogram enclosed as Annex-A) which function on entirely different disciplines
related to minerals affairs, out of which one Resource Mapping Division, second Minor Minerals
Licensing division are different and separate functional units with entirely different functions and
scope of Work. Licensing Division deals entirely with the Minor Minerals chapter of PMC rules,
2002, from the creation of minor minerals blocks/zones, locations of mineral blocks/zones,
reserve price estimation, grant/licensing of blocks/zones and subsequent regulation/monitoring
through Director Licensing Minor Minerals, Punjab and its regional/sub-regional offices of
Deputy Director/Assistant Director Mines and Minerals. Whereas Resource Mapping Division
deals with the exploration activities of major minerals strictly in terms of ADP scheme only and
does not perform any direct function related to Minor Minerals/ Licensing Division under PMC
rules 2002 and other chapters of PMC rules as well. Further, undersign the Manager, Resource
Mapping Division has no direct function and role in minor mineral licensing division beside not
even aware of any routine activities like creation/grant of zone, reserve price facts & figures
estimation & auctioning taking place inside minor minerals division. The undersign is a Regular
Manager of Resource Mapping Division against a regular post and may not be confused as the
Project Manager of Subject Lease. Job Description of Manager Cartography & Survey is
enclosed as Annex-B.

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2. That the Secretary Mines and Minerals Punjab constituted a special expert committee for
determination of Reserve Price for blocks/zone of Minor Minerals under rule 197 A of PMC
2002(Copy Enclosed as Annex-C), and incorporated members from different divisions and
departments vide notification dated January 27, 2016 as Annexure D., where in the Director
Licensing Minor Minerals, Punjab acts as a Chairperson of the committee and the Deputy
Director /Assistant Director Mines and Minerals of the Regional/Sub office concerned as
Member/ Secretary of the Committee. Both are mandatory members being the custodian of all
relevant facts & figures which originates from activities of blocks/zones creation, reserve price
facts & figures estimation & auctioning process. The role of undersign according to job
Description of the post and as per rule 197-A in determination of reserve price is only to examine
description of the geology of the block/zone prepared/presented by the field office & Director
Licensing Mines & Minerals, Punjab. Further it is to be noted that Director Licensing Minor
Minerals, Punjab and the Deputy Director /Assistant Director Mines and Minerals of the
Regional/Sub office are empowered under PMC rules 2002, to create blocks/zones of Minor
Minerals, its reserve price estimation on proforma prepared under Rule 197-A (factors), and
specification of other necessary facts and figures for grant of Minor Minerals blocks. In this
regard, information of only determining factors under rule 197 A i.e nature of mineral reserves,
location, accessibility, its market and adjacent blocks/comparison etc. are briefed to Expert
Committee by the Director Licensing Minor Minerals, Punjab and Assistant Director Mines and
Minerals of the Sub office, only evaluated figures of last operative bids and proposed bids are
added in a circular agenda as and when Expert Committee meeting is scheduled by the Director
Licensing Minor Minerals, Punjab. During the meeting, detail of determining factors is briefed
on multi-media in a meeting room. Further, Expert Committee examines the reserve price on
the basis of profile of the subject zone/block duly estimated by the concerned field office by
considering the factors defined under rule 197 A and not beyond in any case. The authenticity
of the profile (working paper of reserve price) prepared under rule 197 A is dependent on the
data compiled by the concerned field office and Director Licensing Minor Minerals. If in case no
discrepancy is found in briefed details in the light of above rule, the same may be considered
approved by the Expert Committee in the light of estimations carried out by the concerned field
office and this may be forwarded by the Director Licensing Minor Minerals for further
approval/ratification to the Competent Cabinet Committee vide notification dated 2 Feb 2016

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 (Annexure E). Therefore the role of the Expert Committee is dependent on the details and data
briefed/compiled by the Director Licensing and his DD/AD during the meeting, who are the
chairperson and the member/secretary of the Committee as well. Other members of the expert
committee cannot inspect the subject block/zone for fact findings which is being submitted by
the Chairperson of the Committee(Director Licensing Mines & Minerals) & Secretary of the
committee(Concerned Deputy Director/Assistant Director of the field) for reserve price
estimation/determination under PMC rules 2002. So the member of the Expert Committee other
than Director Licensing Minor Minerals, Punjab and Assistant Director Mines and Minerals of
the Sub office, cannot be held responsible if their opinion come to be in consonance with the
details briefed to expert committee and rule 197-A of PMC rules 2002.

In view of the above mentioned role of Divisions and officers and the factual
position in the whole procedure of Grant of Leases of Minor Minerals the para wise
comments/reply of the inquiry findings/allegations produced in FIR No. 43035-03/19 are
given as under:-

Allegations Comments/Reply
Illegal and unjustified  Denied being irrelevant in respect of u/s functions & duties.
creation of new zone for It has already been mentioned above that creation of Minor
gravel & sand in violation Minerals Zones/Block is strictly domain of Director Licensing
of relevant rules & Minor Minerals, Punjab and the Deputy Director /Assistant
regulations on Indus River Director Mines and Minerals of the Regional/Sub office who
Waisa Khurd Attock with are empowered under PMC Rules 2002 to create any new
malafide intention to pave zone or block. So that, there is no role of undersign.
the path for extraction of
placer gold from the site.
Reduction of the reserve  Denied being incorrect on grounds of unjustified
price alleged the newly calculations & giving undo benefit to the contractor because
created zone Rs. undersign is totally unaware about any correspondence
30,33,70,000/- to Rs. held between Licensing division to Admin Department or
100,000,000/- without any with anyone else regarding subject zone. It is apprised that
justified calculation just to undersign acted as a member of Reserve Price Committee

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give undo benefit to the due to non-availability of Director Resource Mapping
contractor company M/S Division HQ’s on 19.5.2017 wherein RS. 303,370,000 was
Hai Hong Super park estimated as reserve price of Sand Gravel zones on the
private limited. Hence basis of demand of 1,720,800 Cubic meter for Motorway
loose of billion rupees were Project (Burhan to Havelian) and sale price of per cubic feet
caused to the state comes to tune of 145,848,000 adding 8 % of as weightage
exchequer. percentage and 100% of base price as unique factor due to
the presence of Gold Particles(Below Deduction Limit).
Hence total amount come to the tune of Rs.303,370,000.
This calculation was estimated by the field office alongwith
Chairperson committee being the most relevant of the
domain having all details of the subject zone. The
concerned field office apprised to the committee that this
estimation is based upon the request of applicant company
M/s China Haihong International Construction Engineering
Co.Ltd. Further, it is to be noted that the role of members in
deciding the reserve price/revision of reserve price is
dependent upon the facts & figures presented by the
concerned Director Licensing Minor Minerals, Punjab and
the Assistant Director Mines and Minerals of the Sub office
who are relevant authorities under PMC Rules 2002. For
instance, to differentiate the role of members in the initial
decision of this case is reproduced as under:-
“The Special Expert committee Considered above reserve price
estimated by the field office Attock and after thorough
deliberations committee is agreed to approve the reserve price
of Rs 303,370,000 /- for Sand Gravel Waisa Attock Khurd Indus
River Zone Tehsil & District Attock”.
In this decision the role of concerned filed office is clearly
expressed in terms of estimation of reserve price under Rule

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197-A and rest of the members cannot deny the facts & figures
due to their limited roles.
Director Licensing Minor Minerals, Punjab through letter dated
10.10.2017 scheduled a meeting on 16.10.2017 alongwith
agenda having 67 blocks/zones list including subject Waisa
Khurd Sand/gravel Zone. This agenda contains details of last
operative & proposed bids (Annexure F) wherein proposed
revised reserve price was already mentioned. In meeting the
concerned Director Licensing Minor Minerals, Punjab and
Assistant Director Mines and Minerals of the Sub office showed
the bid sheet and briefed that no bid has been received for three
consecutive auctions for subject zone, therefore, the Director
Licensing Minor Minerals, Punjab through Assistant Director
Mines and Minerals Sub-office Attock, intends to revise the
previous reserve price Rs. 303,370,000/- to Rs. 100,000,000/-
on the basis of factual position on ground which were briefed by
the them as under:-
I. 90% completion of motorway project(E-35)
from Burhan Interchange (M-1 to Havelian)
II. NHA information that use of sand/gravel
material from the subject area is not
approved for the motorway project
III. Very high reserve price.
During the meeting the Director Licensing Minor Minerals,
Punjab and Assistant Director Mines and Minerals Sub office AD
Attock who also happened to be officer from the Licensing
Division briefed that the revised reserve price is thoroughly
estimated on the basis of ground facts, nature of the deposit, its
market and adjoining blocks and unique factor. And the project
is almost near to completion and the material in the block has
not been approved by the M/s NHA for use in this project

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therefore the earlier calculated reserve price on the basis of
consumption of material (17,20,800 cubic meters of sand/gravel)
become irrelevant. Hence, the concerned field office and
Chairperson reserve price committee introduced the previously
practiced formula of reserve price calculation of sand gravel
zone on the basis of nature of the deposit in the area, its market
value and reserve price of surrounding sand gravel blocks of
Attock District. Therefore it may be approved in larger public
interest. In this regard, reserve price estimation by the Assistant
Director Mines & Minerals Attock office (being the most relevant
person of the committee) assume to be true picture on the basis
of factual position on ground and hence considered as agreed
by the Expert Committee for public interest. Thereafter the
Director Licensing Minor Minerals, Punjab and the Deputy
Director /Assistant Director Mines and Minerals of the
Regional/Sub office took this reserve price agenda in front of
Cabinet Committee where only Director Licensing Minor
Minerals, Punjab and the Deputy Director /Assistant Director
Mines and Minerals of the Regional/Sub office briefed the
subject matter to cabinet committee for final approval/ratification
of reserve price (Annex- G). As practice, no other member of
special expert committee can attend the meeting of Cabinet
committee except Director Licensing Minor Minerals,
Punjab(Chairperson) and the Deputy Director /Assistant Director
Mines and Minerals of the Regional/Sub
office(Secretary/member) being the most relevant members.
Regarding giving undo benefit to the contractor it is apprised that
committee can neither grant nor auction any zone or block under
the PMC Rules 2002. It is in our knowledge that Director
Licensing Minor Minerals, Punjab advertise zones/blocks in
national newspapers with reserve price as minimum value to

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 start the auction proceedings and anybody can take that
zone/block by giving the maximum bid.
The committee has to determine the reserve price of the area to
be auctioned in the light of criteria enshrined in rule 197-A PMC
2002 and facts & figures produced before the committee. It was
neither authorized to grant the area to anybody else nor it was
intending by the committee to do so.
So that, there is no direct role of undersign in estimation of
reserve price/revision of reserve price because the u/s is
dependent on the facts & figures which are collected, compiled
and briefed by the field office & Director Licensing Mines &
Minerals in expert committee’s meeting & giving undo benefit to
the contractor.
The contractor company  Denied being irrelevant on grounds of award of contract. It
Haihong Super park has worth to mention that creation, regulation, auction,
private limited by joining monitoring, control and authority for the cancelation of
hands with functionaries of Lease in case of violation of prescribed rules as given in
Mines & Minerals agreement is strictly domain of Director Licensing Minor
Department Government Minerals, Punjab and the Deputy Director /Assistant
of the Punjab obtain award Director Mines and Minerals of the Regional/Sub office. So
of the newly created zone that, there is no role of undersign.
apparently for extraction of
the sand gravel but in
violation of the relevant
rules & laws the contractor
company subsequently
started extraction of placer
Gold at the site. Therefore
they caused lose in billions
of rupees to the
Government Exchequer.

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 In view of the above facts and figures, it is hereby prayed that the name of undersign may be
withdrawn from the FIR and exonerated from the allegation levelled therein, being innocent. As having
no role in view of above facts in the controversial award of sand gravel zone to a bidder criminally
misrepresenting the facts and misusing national organization’s name for illegitimate gains.

(Rafiullah Khan)
Manager Resource Mapping
Directorate General of Mines & Minerals
Lahore, Punjab

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